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SerbiaChecked 18 August 2026
Yes, with paperworkWork: HighEnforcement: Active
In one paragraph
Serbia copied Europe's privacy law almost word for word, so the duties feel familiar. Data can leave the country, and for most of Europe and a long list of other countries it can leave with no paperwork at all. The privacy regulator is busy — over a thousand inspections in 2025 — but it hands out warnings, not fines. The biggest fine any Serbian court imposed for a privacy breach in 2025 was about $950.
The catch
Two industries break the general picture. Online gambling operators must keep a copy of their whole player and transaction database physically inside Serbia. Banks, insurers and other financial firms cannot move any IT work abroad without telling the central bank 30 days ahead, proving the foreign country would let Serbian supervisors inspect on site, and risking a veto that forces them to cancel the contract.
Does this apply to me?
Yes. The law reaches a company anywhere in the world if it offers goods or services to people in Serbia, or watches what they do in Serbia. There is no size or revenue threshold to hide behind. If you are caught this way you must appoint a written representative living or based in Serbia, unless your processing is occasional and low risk or you are a public body.High confidence
Can the data leave the country?
Yes, with paperwork — and often with none at all. Serbia treats a very long list of countries as automatically safe: every member of the Council of Europe's data protection treaty, which covers all of Europe plus Argentina, Mexico, Morocco, Mauritius, Senegal, Tunisia, Uruguay, Cape Verde and others, and separately every country the European Union has approved. Sending data there needs no permission and no contract. Everywhere else you sign the Commissioner's standard contract or use approved group rules. Only one industry has a hard wall: online gambling. Banking has a gate rather than a wall.High confidence
What do I have to do to send it abroad?
First check the destination. If it is on the safe list, you need nothing — no contract, no filing, no approval. If it is not, you sign the standard contract the Serbian regulator published in January 2020, or you get approved group-wide rules. If you want to use your own wording instead of the standard contract, the regulator must approve it and has 60 days to answer. As a last resort there are narrow exceptions such as the person's explicit consent.High confidence
Who enforces this — and are they actually working?
The Commissioner for Information of Public Importance and Personal Data Protection, and it is genuinely working. In 2025 it finished 1,169 inspections, received 5,310 cases and issued 102 corrective orders. But it almost never fines. Of those 102 orders, 101 were warnings and one was a ban on processing. It asked the courts to punish only three organisations all year. Banks answer to the National Bank of Serbia instead, and it is fully active. A brand-new Office for Information Security exists on paper since October 2025 but we could find no sign it is running yet.High confidence
How long must I keep it, and when must I delete it?
There is no single national rule. The privacy law says keep data only as long as you need it, and each sector sets its own clock. Online gambling operators must keep every transaction for at least ten years. Phone and internet companies must keep who-called-whom records for exactly 12 months and then destroy them. Anyone selling a phone line must keep the customer's identity check for 12 months after the service ends. Financial firms must keep a live register of every outsourced service, including which countries the data sits in.High confidence
What happens when something goes wrong?
Count three clocks. Privacy breach: tell the Commissioner without delay and at the latest within 72 hours, and if you miss that you must explain why. Cyber incident: if you run an information system the state has classed as important, you have only 24 hours to report it. Then a third clock starts — updates every 24 hours for a serious incident, every three days for a middling one, and a final report within 15 days of the incident ending. Banks report cyber incidents to the central bank instead, promptly, with no fixed hour count.High confidence
What's the trap?
Five. (1) A child can consent for themselves at 15, not 13 or 16 — plan your age gates around 15. (2) A foreign court order or foreign tax authority demand for data is recognised in Serbia only if a treaty backs it, so handing data to an overseas authority on request can itself be unlawful. (3) Individuals, not just companies, can be prosecuted; the regulator has filed 49 criminal complaints since 2010. (4) Dozens of older Serbian laws still contradict the privacy law and were never fixed. (5) The government's official list of safe destination countries has not been touched since 2019 and still names a United States framework that died in 2020.High confidence
What's about to change?
One dated change and several unscheduled ones. From 1 January 2027 the ministry formally takes over supervising the new Office for Information Security, which should mean the office is actually up and running by then. A rewrite of the privacy law is being drafted by a special working group covering video surveillance, biometrics, genetic data and artificial intelligence, and a separate group is drafting an artificial intelligence law. Neither has been published as a bill, so neither is binding.High confidence
Hardest industry wall
  • Online gaming Pravilnik o informaciono-komunikacionom sistemu za priređivanje posebnih igara na sreću preko sredstava elektronske komunikacije
RussiaChecked 18 August 2026
A copy must stayWork: Very highEnforcement: Active
In one paragraph
If you collect personal data from people in Russia, the database you collect it into must sit inside Russia. You may then send a copy abroad, but only after you tell the regulator first and only to a country on its approved list. The United States is not on that list. Breaking the storage rule costs up to 6 million roubles, about $75,000, and leaking data can now put a person in prison.
The catch
The 'copy may go abroad' part disappears in several industries. Payments, electronic money, biometrics, telecoms, internet messaging services, government systems and detailed mapping are hard walls: the data must stay in Russia and no copy may leave. Since 1 September 2025 any company running 'significant' critical infrastructure — which includes most banks, telecoms operators and large energy and health providers — must also run Russian-registered software on those systems.
Does this apply to me?
Yes. The law reaches a foreign company with no office in Russia. It applies whenever you process the personal data of Russian citizens under a contract with them, under any other agreement with them, or on the basis of their consent. There is no size or revenue threshold. Almost every organisation must also file a notice with the regulator before it starts processing, and file a second, separate notice before any data leaves the country.High confidence
Can the data leave the country?
A copy can leave, but the original must stay. When you collect personal data about Russian citizens, the database you record, store, update or retrieve it from has to be physically in Russia. Since 1 July 2025 the law says this as a flat ban on using databases outside Russia for those steps. After that, sending a copy abroad is a separate question with its own paperwork. Several industries are stricter still and allow no copy out at all.High confidence
What do I have to do to send it abroad?
Russia runs an approved-destinations list, so a transfer is banned unless the destination is on it. Before any data leaves you must send the regulator a separate written notice naming the countries, the data and the recipients, and you must first collect written assurances from the recipient about how it will protect the data. If the destination is on the approved list you may start as soon as the notice is sent. If it is not, you must wait, and in practice you will be refused. The United States is not on the list.High confidence
Who enforces this — and are they actually working?
Roskomnadzor, the federal communications and media supervisor, is the data protection regulator. It is a long-established federal service, fully staffed, and it is still issuing binding orders — its most recent inspection check-list order was published on the state legal portal in December 2025. It is not the only enforcer. The security service runs the national cyber-attack reporting system, the technical regulator FSTEC sets security requirements for government and critical systems, and the Bank of Russia supervises banks and payment firms.Medium confidence
How long must I keep it, and when must I delete it?
Both directions apply and they collide. Personal data must be destroyed within 30 days of the purpose being achieved, or within 30 days of consent being withdrawn, and within 10 working days if the processing was unlawful. Against that, staff records must be kept for 50 years, telecoms and messaging metadata for three years, and message content for up to six months. Where a statute sets a minimum, the minimum wins and you keep the data.High confidence
What happens when something goes wrong?
There are at least three clocks and they run at once. You have 24 hours to tell the data regulator that personal data has leaked, and 72 hours to give it the results of your internal investigation. Separately, if the leak came from a computer attack you must report it to the security service's national attack-detection system. Banks and payment firms report to the Bank of Russia as well. Missing the 24-hour notice is itself a fine of up to 3 million roubles, about $37,000.High confidence
What's the trap?
Five things catch people out. First, leaking data is now a crime, and doing it across a border carries up to eight years in prison. Second, repeat leaks are fined as a share of worldwide-style annual revenue, between 1 and 3 percent, with a floor of 20 million roubles, about $250,000. Third, staff files must be kept 50 years, which flatly conflicts with the 30-day deletion duty. Fourth, biometric data can only be handled by a Russian-controlled company using databases in Russia. Fifth, refusing to serve a customer because they will not give biometrics is itself a fine.High confidence
What's about to change?
One dated change is already fixed: from 1 September 2027, Moscow's public bodies move onto a single city technology platform, which will pull a large volume of citizen data into one place. Much more important are the switches the government already holds and can flip with no consultation. The approved-country list can be cut by a single regulator order. Any transfer can be banned outright on security or economic grounds. And the rules for foreign use of Russian mapping technology have been written into the law but never issued.High confidence
Hardest industry wall
  • All industries Федеральный закон от 27.07.2006 № 152-ФЗ «О персональных данных», статья 18 часть 5
  • All industries Федеральный закон № 152-ФЗ, статья 21 часть 3.1 и статья 19 часть 12
  • All industries Уголовный кодекс Российской Федерации, статья 272.1
  • Payments Федеральный закон от 27.06.2011 № 161-ФЗ «О национальной платежной системе», статьи 12 и 16
  • All industries Федеральный закон от 29.12.2022 № 572-ФЗ об идентификации и аутентификации с использованием биометрических персональных данных
  • Telecoms Федеральный закон от 07.07.2003 № 126-ФЗ «О связи», статья 64; Федеральный закон от 27.07.2006 № 149-ФЗ, статья 10.1
  • Government Приказ ФСТЭК России от 11.04.2025 № 117; Указ Президента РФ от 30.03.2022 № 166; Указ Президента РФ от 01.05.2022 № 250; Федеральный закон от 07.04.2025 № 58-ФЗ
  • Mapping and location Федеральный закон от 30.12.2015 № 431-ФЗ «О геодезии, картографии и пространственных данных», статьи 23 и 24
  • Health and social care Федеральный закон от 21.11.2011 № 323-ФЗ «Об основах охраны здоровья граждан в Российской Федерации», статья 13
  • Social media and online platforms Федеральный закон от 01.07.2021 № 236-ФЗ «О деятельности иностранных лиц в информационно-телекоммуникационной сети «Интернет» на территории Российской Федерации»